1. This statement should be read in conjunction with the BOT Investment Policy (BOT IV.H) and is subject to periodic review and modification by the Finance Committee for Investments. State law RSA 292-B, also known as the Uniform Prudent Management of Institutional Funds Act ("UPMIFA"), forms the conceptual framework for USNH investment policies, guidelines and procedures for both endowment and non-endowment funds.
2. General Guidelines
2.1 Cash Collection and Concentration. The Treasurer will ensure that cash will be collected throughout USNH and concentrated into central demand deposit account(s) as quickly as practical to assure effective custodianship of assets and to enable productive use of cash to pay expenses and/or to maximize investment opportunities.
2.2 Cash flow Projections. The Treasurer will forecast working capital needs on a rolling basis by reviewing actual cash flows for the past 24 months and forecasting projected cash flows for the next 24 months, taking into account all available information and assumptions regarding trends, capital projects, debt self-liquidity commitments, anticipated internal borrowing, anticipated uses of reserves, and similar sources and uses of cash.
2.3 Liquidity Needs. The Treasurer will maintain adequate liquidity to meet expenses when due and will manage the maturity of investments to maximize investment opportunities consistent with forecasted working capital requirements. The probability of various extraordinary liquidity needs (e.g. capital calls on alternative investments in the endowment fund) will be considered through stress tests so that reasonable risks are factored into liquidity forecasts.
2.4 Due Diligence – Combined Endowment Pool. The Finance Committee for Investments ("Committee") will perform due diligence in the selection and monitoring of the endowment investment advisor, investment managers and investment vehicles. The investment advisor meets with the Committee several times each year. Major investment managers meet with members of the Treasurer’s Office and/or the Committee on a rotating periodic basis.
2.5 Due Diligence – Other Than The Combined Endowment Pool. The Treasurer's Office will perform due diligence in the selection and monitoring of the investment advisor, if applicable. The Treasurer's Office, in consultation with an independent investment advisor, if applicable, will perform due diligence in the selection and monitoring of investment managers and investment vehicles.
2.6 Investment Brokers. Agreements with all brokers, if applicable, defining scope of services and responsibilities will be updated annually and kept on file. Brokers will be asked annually to (a) sign a statement that they have received and reviewed the USNH investment policy and guidelines, and (b) provide a copy of their firm’s audited financial statements and insurance certificate.
2.7 Reporting and Monitoring. Detailed reports and analyses of the most recent investment results of the Combined Endowment Pool are presented to the Committee by the investment advisors on a quarterly basis, and summary reports are provided to the Treasurer on a monthly basis. Quarterly detailed reports are reconciled by USNH Controller's Office staff. Monthly monitoring and reconciliation of investment account statements and analytical reports by the manager is conducted by USNH staff.
2.8 Downgrades of Investments Below Minimum Ratings. If any security or other investment that requires a minimum rating is downgraded below that minimum after purchase, it will no longer be considered a "permitted investment." Prudent measures shall be taken to liquidate the investment in an orderly fashion to reduce loss of principal.
2.9 Implementation of Committee Actions. For investment transactions approved by the Committee, the resolution of any significant post-approval implementation details will be delegated to the Treasurer and the Committee Chair.
3. Categories of Pooled Investments
3.1 Cash and Daily Liquidity Investments
3.1.1 Self-liquidity requirement for variable rate bonds. From time to time, the System may be a guarantor on all or a portion of its variable rate demand bonds, thereby guaranteeing payment of the purchase price of any of such bonds that are tendered for purchase and not remarketed. If there is a failed remarketing, the System will be notified by 11:30 a.m. and must ensure full payment for bonds that are tendered by 3:00 p.m. on the same day. USNH has committed to maintain balances in 2A-7 compliant money market accounts at all times equal to at least 1.5 times the current purchase price of such bonds to ensure adequate same-day liquidity. (See also USNH Financial Procedure 4-120 "VRDB Self-Liquidity Procedure" for more detailed information).
3.1.2 Purposes. To meet the self-liquidity requirement for any such bonds, as detailed above; and to meet the anticipated day-to-day operating and capital cash obligations of USNH. Management will consider the overall environment and economic conditions when making decisions about what level of cash and daily liquidity should be maintained above the minimum 2A-7 compliant money market accounts required by USNH's self-liquidity commitment, if any.
3.1.3 Investment objectives in order of importance. (1) safety of principal, (2) same day liquidity, and (3) consistent with the first two objectives, less regard for rate of return.
3.1.4 Permitted investments. Investments with daily liquidity to meet the self-liquidity requirement on related bonds will be maintained in AAA-rated money market funds complying with SEC Rule 2A-7 (setting strict standards for quality, diversification, and maturity) with the largest national fund managers. Other permitted investments with same-day or next-day liquidity include US Treasury Bills; securities of US Government-backed or guaranteed Agencies and Government Sponsored Enterprises (including but not limited to Federal Home Loan Bank, Federal National Mortgage Association, Government National Mortgage Association) securities with maturities of 3 years or less; overnight repurchase agreements with appropriate collateralization (Treasuries @ 102% or Agencies @ 103%) or other means of mitigating custodial credit risk; and bank deposits.
3.2 Near-term Operating & Capital Obligation Investments
3.2.1 Purposes. To meet the anticipated near-term operating and capital cash obligations of USNH for (including funds needed for anticipated internal borrowing, plant construction commitments, etc.) up to approximately 18 months, and to provide a liquid source of funds in the event the Cash and Daily Liquidity Investments are insufficient to meet USNH's cash needs.
3.2.2 Investment objectives in order of importance. (1) reasonable safety of principal, (2) same day to 30 day liquidity, and (3) consistent with the first two objectives, an above-market rate of return, mostly in the form of dividends and interest income.
3.2.3 Permitted investments. These balances may be maintained in securities permitted in the Daily Liquidity Investments as well as the following: securities of US Government-backed or guaranteed Agencies and Government Sponsored Enterprises (including but not limited to Federal Home Loan Bank, Federal National Mortgage Association, Government National Mortgage Association) securities with maturities of greater than 3 years; high quality bond mutual funds with the largest national fund managers and with up to an average of 3 years duration for the portfolio; high quality domestic fixed income securities and other fixed or floating rate securities of domestic corporations or municipalities with long-term investment ratings by Standard & Poor's and Moody's of AA/Aa or better and maturities of up to 365 days; commercial paper and other securities of domestic corporations or municipalities with investment ratings by Standard & Poor's and Moody's of A1/P1; negotiable certificates of deposit, bankers' acceptances, commercial paper and other floating or fixed rate notes or instruments issued by banks with a similar high rating by an independent rating service, FDIC or FSLIC Insurance, and a demonstrated record of profitability; and similar securities that can be readily converted to liquid cash with a minimal fluctuation of principal value that are domestic, dollar-denominated, non-leveraged, non-derivative, marketable securities registered with the Security and Exchange Commission.
3.2.4 Use of Reserves. The use of reserves impacts the amount of available Operating and Capital funds and therefore requires careful evaluation and planning. Unbudgeted use of reserves as defined in BOT IV.B.2.6 must be approved in advance by the Financial Affairs Committee. Planned use of reserves on any campus greater than $1 million must be communicated as far in advance as possible with the Treasurer's Office to aid in preparing accurate cash flow and fund balance projections.
3.3 Excess Cash, Daily Liquidity Investments and Near-Term Operating & Capital Investments
3.3.1 Purpose. To optimize earned income on long-term funds which will be expended by USNH only in the event of severe financial emergency or unusual capital and/or operating needs.
3.3.2 Investment objectives in order of importance. (1) an above-market total rate of return averaged over a number of years, and (2) consistent with the first objective, a measured tolerance for risk and adequate liquidity.
3.3.3 Permitted investments. These balances will generally be maintained in diversified fixed income securities with maturities of over 365 days and equity or bond mutual funds with intermediate to long durations. Alternatively, these funds may be invested alongside the endowment in the Combined Endowment Pool (below), or with appropriate Chancellor or Financial Affairs Committee approval, may be added to the CEP as a quasi-endowment (see BOT IV.G.3), with or without adoption of the standard spending formula.
3.3.4 Allocation of available Excess Cash & Daily Liquidity Investments funds. Amounts above the minimum specified in section H.3.3.1 may be moved to Near-Term Operating & Capital Investments at the discretion of the Treasurer, or directed on an annual basis to the Long Term Treasury Investments quasi-endowment fund in the Combined Endowment Pool at the recommendation of the Investment Committee and the approval of the Financial Affairs Committee.
3.4 Combined Endowment Pool ("CEP")
3.4.1 Purpose. To maximize total returns over a very long time horizon and to support intergenerational equity by employing spending levels which will maintain market value in real terms (i.e., adjusted for expected inflation in the cost of the supported programs and services) in perpetuity, balancing current and future needs specified by the individual endowment fund. Individual endowments purchase units in the CEP monthly based on the current market value per unit.
3.4.2 Investment objectives in order of importance. (1), an above-market rate of total return using a five year planning horizon and (2) consistent with the first objective, a measured tolerance for risk and adequate liquidity.
3.4.3 Permitted investments. These balances will generally be maintained in equities, fixed income, and alternative investments with varying maturities.
18.104.22.168 Asset allocation. Target asset allocations are designed to provide broad diversification of asset categories and investment styles with the objective of minimizing downside risk while capturing upside returns. Expected returns and risks are modeled on a periodic basis by the investment advisor to determine an appropriate target asset allocation given the Committee's risk/return objectives. The Committee will review the actual and target allocations at least annually and affirm or revise specific allocation targets.
22.214.171.124 Liquidity. Increased investment returns often come at the price of illiquidity. Liquidity allocation parameters therefore seek to permit potentially higher yielding illiquid investments while managing certain key risks: diminished marketability of endowment assets, reduced transparency of fund manager decisions, and delayed release of investment performance and valuation information. The target allocation for illiquid investments is 15%, with a maximum limit of 20%.
126.96.36.199 Strategic asset allocation targets. The following table reflects the current allocation targets.
|Target Asset Allocation (%)||Lower (%)||Upper (%)|
|Total Global Public Equity||50||40||60|
|Total Flexible Capital||30||20||35|
|Global Fixed Income||10||5||20|
|Total Liquid Capital||0||15|
188.8.131.52 Targets for alternative assets. It is understood that because some of the targeted allocations include alternative investments the actual investment allocation may not precisely align with the respective target allocation. Private equity and venture capital investments in particular often have long lead times to completely fulfill committed capital draws, and can make capital distributions which contribute to imprecise target allocations. Allocation ranges, as specified in H.184.108.40.206 above, allow for such timing and valuation variations.
220.127.116.11 Valuation of alternative assets. Every attempt will be made to obtain timely and accurate valuations each month/quarter from alternative asset managers. Where estimated valuation reports are not received within 30 days of period end, the USNH Controller's Office, in conjunction with the investment advisors, will roll forward the previous period’s amounts by reflecting any additional investments, capital calls, return of capital, etc., and will contact the manager to obtain oral or other evidence of the appropriate value. Stated valuations for the major funds or funds-of-funds will be tested for reasonableness by conferring with the fund manager and/or investment advisor to review significant events or economic conditions which may have had a material effect on the fund value. With the assistance, as needed, of the investment advisor, the USNH Controller's Office is responsible for understanding the valuation methods and accounting principles used by each major fund and for assigning its best, objective estimate of valuations in the year end audited USNH financial statements.
18.104.22.168 Allocation Ranges and Rebalancing. Depending on the asset type, actual allocations typically are allowed to vary within a stated range, as specified in H.22.214.171.124 above. This is acceptable for tactical over or under-weighting, for changes in market values of various components over time, and to allow for the investment and valuation idiosyncrasies of certain alternative investments as discussed in H.126.96.36.199 above. Rebalancing will be considered on a periodic basis to maintain actual asset allocations within acceptable ranges of the strategic targets.
188.8.131.52 Treasurer's management responsibilities. With respect to newly received gifts and other funds for endowment and non-endowment purposes as well as for cash holdings above the approved target, the Treasurer will cause all such funds to be invested in an orderly and timely fashion according to approved asset allocation targets and existing investment vehicles, giving due consideration to liquidity needs for payout distribution.
3.4.4 Standard spending formula. The standard spending formula is recommended by the Finance Committee for Investments and approved each year by the Financial Affairs Committee.
184.108.40.206 Objectives. The standard spending formula will be established such that the endowment funds can continue to pay out annual amounts in perpetuity, without a reduction in purchasing power. For example, if an endowment fund provides for one in-state tuition scholarship today it will be expected to provide for one in-state tuition scholarship 25 years from now. This contemplates increased tuition costs at levels which have historically increased slightly higher than the consumer price index. This increased level of future costs could be assumed to be 2% above the historical average CPI in recent years of 2.5%. In other words, USNH may target 4.5% growth in the invested balance of an individual endowment fund over a very long time horizon. Other objectives of the standard spending formula include (a) predictable and dependable annual payout amounts to support ongoing programs and services; (b) timely annual payout data to enable departments to incorporate estimated payouts in annual budget development; and (c) to the extent possible, maintenance of similar payout policies with the UNH Foundation.
220.127.116.11 USNH institutional variances. The standard spending formula, both for purpose and for an administrative fee as provided under guidelines by the state Attorney General, may vary by USNH institution.
18.104.22.168 Payout for purpose. To avoid a rebuttable presumption of imprudence per UPMIFA, RSA 292-B:4 VI, the standard spending formula for purposes specified by donors will not exceed a specified percentage of the prior year's payout amount per unit, limited by 7% of the 12-quarter moving average of the endowment fund’s market value for the period ending the preceding June 30.
22.214.171.124 Payout for administration. Per State of NH Attorney General guidelines, the standard
spending formula for an administrative fee may not exceed 1% of the market value per unit as of the preceding December 31 without regard to the limitations in H.126.96.36.199 above.
4. Mitigation of Credit Risk for the System is defined to include all Cash and Investments excluding the UNH Foundation (UNHF), Keene Endowment Association (KEA) and any other separately invested assets of the System.
4.1 Credit Risk. Credit risk is the risk of loss of principal due to default of the security issuer. Credit risk will be mitigated by (a) due diligence in the selection and continuing review of competent investment managers, and (b) diversification of investments and investment managers, as follows:
4.1.1 USNH's direct investment in any one entity's commercial paper may not exceed $10 million.
4.1.2 Except in unusual circumstances (such as the temporary government guarantee program), no more than $50 million may be invested in any one money market fund, mutual fund, hedge fund, or fund-of-funds. Except in unusual circumstances, no more than $75 million may be invested with any one bank, fund manager, or investment house for the combined funds of the categories of pooled investments per sections H.3.1-3.4 above.
4.1.3 With respect to CEP credit risk exposure, no more than 10% of the CEP may be invested with any one active manager/sponsor, except as specifically permitted by the Finance Committee for investments.
4.1.5 USNH investments as a percentage of an institution's net equity may not exceed 20%.
5. Measurement of Investment Performance
5.1 Performance Evaluation Benchmarks
Benchmarks are useful to gauge the performance of USNH's investments, but they are best considered over longer periods, generally three-to-five years. The specific benchmarks and weighting for the CEP will be formalized in cooperation with the investment advisor. The performance of the Fund's investment managers will be actively monitored by the Investment Committee, the Treasurer and/or the investment consultant, who will report any meaningful observations and performance deviations in a timely manner. Quarterly performance will be evaluated versus appropriate benchmarks and peer universities, but emphasis will be placed on relative performance over longer investment periods.
5.2 Quarterly Reporting. Investment results are compared to stated indices no less frequently than quarterly.